SEC Comment Letter for ODYSSEY MARINE EXPLORATION INC (OMEX) (CIK 0000798528) (OMEX) — Oct 7, 2013
ODYSSEY MARINE EXPLORATION INC (OMEX) (CIK 0000798528)
Date: Oct. 7, 2013 · CIK: 0000798528 · Accession: 0000000000-13-055270
AI Filing Summary & Sentiment
File numbers found in text: 001-31895
Referenced dates: October 1, 2013, September 11, 2013
Letter
October 7 , 2013 Via E-Mail Mr. Michael J. Holmes Chief Financial Officer Odyssey Marine Exploration Inc. 5215 West Laurel Street Tampa, FL 33607
Re: Odyssey Marine Exploration, Inc. Form 10-K for Fiscal Year E nded December 31, 2012 Filed March 12, 2013 File No. 001-31895
Dear Mr. Holmes :
We have reviewed your letter dated October 1, 2013 , in response to the Staff’s letter dated September 11, 2013 and have the following additional comment. Please revise your disclosure in future filings in response to our comment. Your response should be submitted in electronic form, under the label “corresp” with a copy to the staff. Please respond within ten (10) business days. Note A . Organization and Summary of Significant Accounting Policies, page 38 Revenue Recognition and Accounts Receivable. 1. We note from your response to our prior comment number 6 that you will revise the notes to your financial statements in future filings to explain the recognition of revenue for bulk silver bullion. Please also revise to explain how you recognize deferred r evenue for amounts which Galt earns under the revenue participation agreement and for the expenses that you are reimbursed for under your agreement with the United Kingdom Government for the Gairsoppa project. Your revised disclosures should be presented i n a level of detail consistent with your response to our prior comment number 6.
Mr. Michael J. Holmes Odyssey Marine Exploration Inc. October 7 , 2013 Page 2
You may contact Effie Simpson at (202) 551 -3346 , or in her absence, the undersigned at (202) 551 -3750 if you have questions regarding comments on the financial statemen ts and related matters. Please contact the undersigned with any other questions.
Sincerely,
/s/ Linda Cvrkel
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October 7 , 2013
Via E-Mail
Mr. Michael J. Holmes
Chief Financial Officer
Odyssey Marine Exploration Inc.
5215 West Laurel Street
Tampa, FL 33607
Re: Odyssey Marine Exploration, Inc.
Form 10-K for Fiscal Year E nded December 31, 2012
Filed March 12, 2013
File No. 001-31895
Dear Mr. Holmes :
We have reviewed your letter dated October 1, 2013 , in response to the Staff’s letter
dated September 11, 2013 and have the following additional comment. Please revise your
disclosure in future filings in response to our comment. Your response should be submitted in
electronic form, under the label “corresp” with a copy to the staff. Please respond within ten
(10) business days.
Note A . Organization and Summary of Significant Accounting Policies, page 38
Revenue Recognition and Accounts Receivable.
1. We note from your response to our prior comment number 6 that you will revise the notes
to your financial statements in future filings to explain the recognition of revenue for bulk
silver bullion. Please also revise to explain how you recognize deferred r evenue for
amounts which Galt earns under the revenue participation agreement and for the expenses
that you are reimbursed for under your agreement with the United Kingdom Government
for the Gairsoppa project. Your revised disclosures should be presented i n a level of
detail consistent with your response to our prior comment number 6.
Mr. Michael J. Holmes
Odyssey Marine Exploration Inc.
October 7 , 2013
Page 2
You may contact Effie Simpson at (202) 551 -3346 , or in her absence, the undersigned at
(202) 551 -3750 if you have questions regarding comments on the financial statemen ts and
related matters. Please contact the undersigned with any other questions.
Sincerely,
/s/ Linda Cvrkel
Linda Cvrkel
Branch Chief